Larry G. and Mary L. Bangs - Page 9

                                         -9-                                          
               Respondent’s revenue agent sent petitioners a number of                
          documents in September 2003 to resolve all non-farming activity             
          issues after she reviewed petitioners’ pro forma returns.  These            
          documents included Form 4549A, Form 870, Waiver of Restrictions             
          on Assessment, Form 906, Closing Agreement Covering Specific                
          Matters (the closing agreement), and Form 872, Consent to Extend            
          the Time to Assess Tax.  Petitioners needed to extend the period            
          of limitations because the period for 1999 would soon expire.               
               The closing agreement resolved the dispute relating to the             
          proper treatment of the trusts.  In it, the parties agreed that             
          the trusts would be disregarded and the trusts were petitioners’            
          alter egos.  Petitioners also agreed that they would report on              
          individual returns for 1999 and subsequent years all income,                
          expenses, and deductions, as allowed by the Code.  In addition,             
          the parties agreed that petitioners would be liable for                     
          additional taxes, penalties, and interest on their individual               
          returns due to collapsing the trusts.                                       
               Petitioners signed each document and returned them to the              
          revenue agent.  Respondent also executed the closing agreement.             
          Shortly after petitioners signed these documents, the revenue               
          agent discovered that she had made errors in the Form 4549A                 
          petitioners signed.  The revenue agent had inadvertently omitted            
          interest income that petitioners had shown on their pro forma               
          returns, and she miscalculated the amount of capital gains.                 
          Petitioners apparently did not notice these mistakes when they              






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